Open Recommendations
Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
---|---|---|---|---|---|
3 | No | $0 | $0 | ||
We recommend that the Board chair or a designee develop a plan for how to further enhance uniformity across the System’s financial disclosure report review process, including considering additional controls and guidance. | |||||
5 | Yes | $0 | $0 | ||
We recommend that the Board chair or a designee develop a process to verify the accuracy of the information on financial disclosure reports for individuals subject to the Investment and Trading Policy. As part of this effort, a. require covered individuals to provide brokerage statements to their respective ethics officer for all accounts with holdings and transactions reported on their annual financial disclosure report.b. update financial disclosure review guidance to include the use of employee-provided brokerage statements to check annual financial disclosure reports for accuracy and completeness. | |||||
6 | No | $0 | $0 | ||
We recommend that the Board chair or a designee develop an approach to verify the accuracy of the information on financial disclosure reports for individuals who have access to confidential Class I FOMC information and are not covered by the Investment and Trading Policy. As part of this effort,a. determine the method and frequency for checking the accuracy and completeness of financial disclosure reports against brokerage statements, for example, by conducting periodic random sampling or full reviews.b. update financial disclosure review guidance to include the use of employee-provided brokerage statements to check annual financial disclosure reports for accuracy and completeness and describe the method and frequency of this review.c. assess the costs and benefits of establishing a system to automatically detect prohibited assets or failure to preclear trades using employee-provided brokerage statements and determine whether to implement such an automated approach. |